-2- MEMORANDUM FINDINGS OF FACT AND OPINION CHABOT, Judge: Respondent determined deficiencies in Federal individual income tax and additions to tax under section 6662(a)1 (accuracy-related) against petitioner as follows: Additions to tax Year Deficiency Sec. 6662(a) 1993 $5,471 $1,094 1994 6,969 1,394 1995 8,341 1,668 After concessions,2 the issues for decision are as follows: 1. Whether petitioner’s Schedule C activity of making and selling videotapes (hereinafter sometimes referred to as petitioner’s videotape activity) was “not engaged in for profit” within the meaning of section 183 for 1993 through 1995; and 2. Whether petitioner is liable for negligence additions to tax under section 6662(a) for 1993 through 1995. 1 Unless indicated otherwise, all section and chapter references are to sections and chapters of the Internal Revenue Code of 1986 as in effect for the years in issue. 2 The parties have stipulated that (1) petitioner paid or incurred all the expenses reported on his Schedule C for each of the years in issue, (2) these expenses are not “start-up expenditures” within the meaning of sec. 195, and (3) if the Court holds that petitioner’s videotape activity constituted a trade or business, then all these expenses are deductible.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011